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Case 1:20-cr-00330-AJN Document 87 Filed 12/04/20 Page 2 of 4 The Honorable Alison J. Nathan November 30, 2020 Page 2 With regard to the November 25" Letter, Ms. Maxwell requests redaction of three sentences. The first sentence must be redacted because it contains information that will identify a proposed co-signer. The government, itself, concedes that such information should be redacted. (See November 25" Letter at 3). The reference in this sentence to Even assuming, arguendo, that there is some minimal public interest in knowing the identity of a particular surety, it is vastly outweighed by the significant privacy concerns in this case. See United States v. Amodeo, 71 F.3d 1044, 1050-51 (2d Cir. 1995) (“[t]he privacy interests of innocent third parties ... should weigh heavily in a court’s balancing equation.... [C]ourts have the power to insure that their records are not used to gratify private spite or promote public scandal[.]”).! Similarly, redaction of the second and third sentences, like the first, is necessary to protect the privacy and safety of people who have suffered, or legitimately fear they will suffer, terrible personal and professional consequences for having been linked to Ms. Maxwell. People close to Ms. Maxwell have been physically stalked by members of the tabloid press and have had aparazzi jump out of bushes and in front of their cars to snap pictures of them. And several have been the target of repeated physical threats. Many of the people who want to support Ms. Maxwell’s renewed bail application are older and do not have the financial means to hire a personal security detail to protect themselves. Nor should they have to. They are all people of good character who are simply trying to support Ms. Maxwell’s constitutional right to seek release on bail. They should be given appropriate protections so that they can step forward without having their lives upended or, worse, destroyed. The November 25" Letter, as submitted, intentionally avoided naming these individuals for this very reason. But removing or redacting their names, as the government proposes, is not enough. This case has generated so much media attention and public opprobrium that public eee. * Given the sensitive subject matter of this case, the sureties have legitimate fears for their safety if they are publicly identified. Numerous social media posts have advocated killing Ms. Maxwell as a perverse form of “justice” for her alleged role in Epstein’s sex trafficking crimes. As we have all been recently reminded with the tragic case of the death of Judge Esther Salas’s son, there are people who are capable of committing horrible acts of violence—even against innocent third parties—by convincing themselves that their actions are justified. DOJ-OGR-00001856